Is Hong Kong Part of China for Tax Treaty Purposes?

The Tax Specialist, Vol. 6, No. 2, pp. 62-67, 2002

6 Pages Posted: 27 Aug 2011

See all articles by Jason Chang

Jason Chang

KPMG

Richard Krever

University of Western Australia Law School

Date Written: October 1, 2002

Abstract

Chinese double tax treaties define the territory of China in a broad sense and prima facie Hong Kong is included within the territory of China. However, the Chinese and Hong Kong authorities, as well as all of China's treaty partners, take the view that Hong Kong is not covered by Chinese tax treaties. This paper considers the problem from the context of a Canadian case, Edwards v The Queen, and the Australia-China tax treaty.

Suggested Citation

Chang, Jason and Krever, Richard, Is Hong Kong Part of China for Tax Treaty Purposes? (October 1, 2002). The Tax Specialist, Vol. 6, No. 2, pp. 62-67, 2002, Available at SSRN: https://ssrn.com/abstract=1917905

Jason Chang

KPMG ( email )

KPMG House
161 Collins Street
Melbourne VIC 3000
Australia

Richard Krever (Contact Author)

University of Western Australia Law School ( email )

M253
35 Stirling Highway
Crawley, Western Australia 6009
Australia

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